Medicaid and Immigrant Eligibility: Navigating Changing Rules and Verification Processes

Medicaid, a cornerstone of the U.S. Healthcare system, provides vital coverage to over 81 million low-income individuals. However, eligibility for immigrants within Medicaid and the Children’s Health Insurance Program (CHIP) is complex and subject to change. This article examines the current landscape of immigrant eligibility, recent policy shifts, and the verification processes states employ.

Who is Eligible?

Eligibility for Medicaid and CHIP is generally limited to U.S. Citizens and certain lawfully present immigrants. This includes:

• U.S. Citizens, nationals, and naturalized citizens
• American Indians/Alaska Natives
• Qualified immigrants, including those Permanently Residing Under Color of Law (PRUCOL)
• Non-immigrants who are lawfully present and New York State residents.

As of 2023, eligible noncitizens represented 6% of Medicaid enrollees under age 65 [2].

Recent Policy Changes and Restrictions

Federal regulations regarding immigrant eligibility for Medicaid are evolving. The 2025 reconciliation law, set to take effect October 1, 2026, will further restrict lawfully present immigrant eligibility for both Medicaid and CHIP [4]. Federal Medicaid funds cannot be used to cover undocumented immigrants, and this exclusion extends to other federally funded health programs like Medicare and the Affordable Care Act (ACA) Marketplaces [4].

In February 2025, an executive order aimed at “ending taxpayer subsidization of open borders” called for enhanced verification systems to prevent unauthorized immigrants from receiving taxpayer-funded benefits and required federal agencies to identify funding sources for undocumented immigrants [4].

How States Verify Immigration Status

States are required by federal rules to verify an applicant’s eligible immigration status through the Department of Homeland Security (DHS) as part of the Medicaid eligibility determination process [4]. New federal Medicaid reverification requirements are also being implemented [4].

Resources for Navigators and Assistance Personnel

Information regarding immigrant eligibility for Marketplace, Medicaid, and CHIP coverage is available to certified Navigators, application counselors, and non-Navigator assistance personnel [3].

Key Takeaways

• Medicaid eligibility for immigrants is restricted to U.S. Citizens and certain lawfully present immigrants.
• Recent legislation will further limit eligibility for lawfully present immigrants starting in 2026.
• Federal funds cannot be used to cover undocumented immigrants.
• States are required to verify immigration status through the Department of Homeland Security.